The Office of Management and Budget (OMB) has released further guidance on how recipients of stimulus funds must report to the federal government. Central to this updated document, are guidelines on how to define job creation and what technical data requirements must accompany reports due in October.

In a memo issued Monday, OMB Director Peter Orszag wrote, “As significant recovery funds have now made their way into local communities and the work to rebuild our economy continues to gain momentum, it is essential that the public have access to information on the manner in which funds are being expended at the local level.”

Among the key questions every recipient will have to answer are:

Who is receiving Recovery Act dollars and in what amounts?

What projects or activities are being funded with Recovery Act dollars?

What is the completion status of such projects or activities and what impact have they had on job creation and retention?

Also included with Mr. Orszag’s memo was updated reporting framework guidance, intended to capture additional spending data from prime and sub-recipients of stimulus funding. OMB and the Recovery Accountability and Transparency Board continue to work on FedrealReporting.gov, which is a Web-based nationwide data collection system that will reduce information reporting burden on recipients by, “simplifying reporting instructions and providing a user-friendly mechanism for submitting required data,” the document said.

The updated guidance spells out the required data by type of recipient, though ultimate responsibility for reporting all data required to the federal government is the Prime Recipient. The following diagram illustrates the basic chain of command for prime and sub-recipient reporting.

In the original draft of OBM guidance regarding reporting requirements, recipients were expected to begin submitting data to the federal government on July 10, 2009. This date has since been moved back a quarter to October 10, 2009. However, the July 2009 date could provide an opportunity for Federal agencies and recipients to solidify logistical solutions, troubleshoot potential data reporting challenges and share best practices for planning and implementing the reporting requirements. So, according to the latest guidance, OMB and the Recovery Board are working together to foster a series of forums, meetings, and small-scale data collection pilots to take place during the month of July 2009.

One section of the updated guidance sure to receive a lot attention in the coming months is one that concerns the Recovery Act’s central theme: Jobs.

Under direction from the new guidance, recipients must account for jobs both in terms of the number of jobs created and the kinds of jobs created or retained. The document also defines the types of jobs that must be counted and those that should not be counted. Part-time or temporary jobs should be converted into “full-time equivalent” jobs, by a given formula. But employment impacts on material suppliers and central service providers, or the local community who are not directly charged to Recovery Act supported projects/activities are not counted as jobs created or retained. The Council of Economic Affairs continues to work on macro-economic methodology to account for the overall employment impact of the stimulus package.

Other important parts of the updated guidance include a nine-step time line of recipient reporting, beginning thirty-five days prior to the end of the quarter and continuing over the next ninety days. As well as a more detailed explanation of how FederalReporting.gov will interact with Recovery.gov. As an addendum to the guidance, OMB and the Recovery Board have issued a Recipient Reporting Data Model V2.0.1, which includes reporting templates, a description of required data elements, and XML Schema definition section.

“The states, companies, and organizations pushing forward with Recovery Act projects have been collecting this data. In turn, we’re putting in place a streamlined, manageable way for them to report and make the information available to the American people,” OMB Director Orszag said.